Minnesota

Campaign Finance andPublic Disclosure Board
THE FOLLOWING PUBLICATION DOES NOT IDENTIFY THE
REQUESTER OF THE ADVISORY OPINION, WHICH IS NON PUBLIC DATA
under Minn. Stat. § 10A.02, subd. 12(b)RE: Campaign Expenditures and Non Campaign Disbursements

ADVISORY OPINION 379

SUMMARY
A principal campaign committee may not pay compensation to its candidate for runningfor office.
FACTS
As an individual interested in recruiting candidates who will run for state office and registerwith the Campaign Finance and Public Disclosure Board (the Board) you request anadvisory opinion based on the following:
1. The time commitment needed for a candidate to campaign for a state office is so
substantial that desirable people may be discouraged from presenting themselves
as candidates on an unpaid basis. You state that this is problem for legislative
candidates and candidates for constitutional office.
2. You anticipate candidates will campaign at public meetings and other events sothat the candidates are available to meet with voters.
3. You propose that candidates would document the time they spend campaigningby keeping a log of the meetings and events they attend along with the number ofhours spent at each event.
4. You are aware of the provisions of Minnesota Statutes section 211B.12 which lists

permitted expenditures that may be made with funds collected for political
purposes.

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Cited Statutes and Administrative Rules
10A.01 Definitions.
Subd. 9. Campaign expenditure. "Campaign expenditure" or "expenditure" means apurchase or payment of money or anything of value, or an advance of credit, made or
incurred for the purpose of influencing the nomination or election of a candidate or forthe purpose of promoting or defeating a ballot question.
An expenditure is considered to be made in the year in which the candidate made thepurchase of goods or services or incurred an obligation to pay for goods or services.
An expenditure made for the purpose of defeating a candidate is considered made for thepurpose of influencing the nomination or election of that candidate or any opponent ofthat candidate.
Except as provided in clause (1), "expenditure" includes the dollar value of a donation inkind.
"Expenditure" does not include:(1) noncampaign disbursements as defined in subdivision 26;(2) services provided without compensation by an individual volunteering personal
time on behalf of a candidate, ballot question, political committee, political fund,principal campaign committee, or party unit; or(3) the publishing or broadcasting of news items or editorial comments by the news
media.
Subd. 26. Noncampaign disbursement. "Noncampaign disbursement" means apurchase or payment of money or anything of value made, or an advance of credit
incurred, or a donation in kind received, by a principal campaign committee for any of
the following purposes:(1) payment for accounting and legal services;(2) return of a contribution to the source;(3) repayment of a loan made to the principal campaign committee by that committee;(4) return of a public subsidy;(5) payment for food, beverages, entertainment, and facility rental for a fund-raising
event;(6) services for a constituent by a member of the legislature or a constitutional officer
in the executive branch, including the costs of preparing and distributing asuggestion or idea solicitation to constituents, performed from the beginning of the3

term of office to adjournment sine die of the legislature in the election year for theoffice held, and half the cost of services for a constituent by a member of thelegislature or a constitutional officer in the executive branch performed fromadjournment sine die to 60 days after adjournment sine die;(7) payment for food and beverages consumed by a candidate or volunteers while they
are engaged in campaign activities;(8) payment for food or a beverage consumed while attending a reception or meetingdirectly related to legislative duties;(9) payment of expenses incurred by elected or appointed leaders of a legislative
caucus in carrying out their leadership responsibilities;(10) payment by a principal campaign committee of the candidate's expenses forserving in public office, other than for personal uses;(11) costs of child care for the candidate's children when campaigning;(12) fees paid to attend a campaign school;(13) costs of a postelection party during the election year when a candidate's name will
no longer appear on a ballot or the general election is concluded, whicheveroccurs first;(14) interest on loans paid by a principal campaign committee on outstanding loans;(15) filing fees;(16) post-general election thank-you notes or advertisements in the news media;(17) the cost of campaign material purchased to replace defective campaign material, if
the defective material is destroyed without being used;(18) contributions to a party unit;(19) payments for funeral gifts or memorials; and(20) other purchases or payments specified in board rules or advisory opinions as beingfor any purpose other than to influence the nomination or election of a candidateor to promote or defeat a ballot question.
The board must determine whether an activity involves a noncampaign disbursement
within the meaning of this subdivision.
A noncampaign disbursement is considered made in the year in which the candidate
made the purchase of goods or services or incurred an obligation to pay for goods orservices.
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211B.12 Legal Expenditures.
Use of money collected for political purposes is prohibited unless the use is reasonably
related to the conduct of election campaigns, or is a noncampaign disbursement asdefined in section 10A.01, subdivision 26. The following are permitted expenditures
when made for political purposes:(1) salaries, wages, and fees;(2) communications, mailing, transportation, and travel;(3) campaign advertising;(4) printing;(5) office and other space and necessary equipment, furnishings, and incidentalsupplies;(6) charitable contributions of not more than $50 to any charity annually; and(7) other expenses, not included in clauses (1) to (6), that are reasonably related
to the conduct of election campaigns. In addition, expenditures made forthe purpose of providing information to constituents, whether or not related
to the conduct of an election, are permitted expenses. Money collected forpolitical purposes and assets of a political committee or political fund may
not be converted to personal use.
4503.0900 NONCAMPAIGN DISBURSEMENTS.
Subpart 1. Additional definitions. In addition to those listed in Minnesota Statutes,
section 10A.01, subdivision 26, the following expenses are noncampaign disbursements:
A. transportation, meals, and lodging paid to attend a campaign school;
B. costs of campaigning incurred by a person with a disability, as defined in
Minnesota Statutes, section 363.01, subdivision 13, and which are made necessary
by the disability;
C. the cost to an incumbent or a winning candidate of providing services to residents
in the district after the general election in an election year for the office held;D. payment of advances of credit in a year after the year in which the advance wasreported as an expenditure; andE. payment of fines assessed by the board.

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